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FINDINGS OF FACT1
Petitioner lived in Greensboro, North Carolina, when he
filed the petition in this case. Petitioner is a civilian
employee of the Defense Department at Camp Lejeune. He works
full time as a pipe fitter for about $20 per hour.
Petitioner filed his income tax returns for 1985 on April
19, 1996, for 1986 on March 27, 1996, for 1987 on April 19, 1996,
for 1992 on April 23, 1995, and for 1994 on March 14, 1996. He
timely filed his 1995 tax return.
Respondent issued a notice of Federal tax lien on September
3, 1996, for 1985, 1986, 1987, 1992, 1994, and 1995, relating to
income tax liabilities that petitioner reported on his return,
less withholding credits and other payments, and including
additions to tax for failure to timely file returns and pay tax,
lien fees, and interest.
Respondent issued a Final Notice, Notice of Intent to Levy
and Notice of Your Right to a Hearing, which petitioner received
on February 17, 1999. See secs. 6330 and 6331. Petitioner filed
a request for a hearing. In it, he stated that “every time I
talk to someone I get a different set of figures”, and that no
1 Petitioner refused before and at trial to stipulate facts
not fairly in dispute as required by Rule 91, including whether
copies of income tax returns with his name and signature for
1985, 1986, 1987, 1992, 1994, and 1995 were his. Thus, the Court
ordered that respondent’s proposed factual stipulations were
deemed established.
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